Regulatory Alerts2006-02-03
Added
Frequently Asked Questions Foreign Bank Recertifications under 31 C.F.R. § 103.177
The guidance establishes that covered financial institutions must obtain foreign bank recertifications on or before the three-year anniversary of the execution date of the initial or previous certification. This policy applies to global recertifications and requires that if a certification is corrected or amended, the three-year recertification period restarts from the execution date of the revised document. Institutions may satisfy safe harbor requirements by obtaining certifications via electronic transmission or other data communication systems.
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